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The GDPR defines a personal dataset as "all information about an identified or identifiable natural person. An individual who can be identified directly or indirectly is regarded as identifiable by means of an identification key such as a name, an identification number, location data, an online identification code or one or more elements which are characteristic of the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person."
We request a limited amount of personal data about you in the following cases:
- When requesting a real-time demo account from WH
- when requesting a free e-book from the WH SelfInvest trading library, or
- when registering for an event (webinar or seminar) organized or sponsored by WH SelfInvest: your surname, first name, e-mail address, telephone number, postcode and country.
- When subscribing to a free newsletter: your surname, first name, e-mail address and country.
- When subscribing to the free BörsenNewsletter or the free UniversBourse newsletter or forum: e-mail address.
- When requesting a book: your surname, first name, address, postcode, country, e-mail address and telephone number.
- When requesting to be contacted by telephone: your surname, first name, e-mail address, telephone number and country.
We request a more extensive amount of personal data about you in the following case:
- When entering into a contractual relationship with WH SelfInvest: the personal data and supporting documentation as requested in the account application.
In addition the following data is collected electronically: cookies and an IP address.
An IP address identifies a PC. Cookies are small information files that are automatically saved on the hard drive of a computer. The information is sent back to the website administrator on each visit and enhances an easier, faster and more efficient access to websites and services. WH SelfInvest installs cookies in order to trace which adverts and promotions visitors used to come to our website.
When you request, for example, an e-book or register for an event the IP address and some cookies become part of the personal dataset.
Most internet browsers allow you to delete cookies from your hard disk or to reject cookies before they are installed. For more information about this, please consult the instructions of your internet browser.
Which cookies do we use?
- Session cookie: the WH SelfInvest websites use an in-house content management system. Such cookies allow us to see which sections of the website have been viewed during a visit. A session cookie allows the system to remember a language choice when browsing.
Session cookies are automatically deleted when you close your web browser.
- Performance cookie: performance cookies collect data on the use of a website such as the source of the visitors and the number of visitors. WH SelfInvest uses its own cookies and Google Analytics for this purpose.
The settings of Google Analytics on the websites of WH SelfInvest are set up in such a way that your IP address is made unrecognizable.
Google uses this information to keep track of how you use our website, to compile reports on website activity for us and to offer other services relating to website activity and internet usage. The Google Analytics settings for the WH SelfInvest websites were set up in such a way that Google is not allowed to share this anonymous information with third parties. However, Google may provide this information to third parties if it is legally obliged to do so. In the framework of the EU GDPR you can read at https://www.google.com/intl/en/policies/privacy/#application that Google adheres to the EU-US Privacy Shield principle, which guarantees the protection of personal data.
Performance cookies are automatically deleted after 12 months.
- Tracking cookie: tracking cookies and related technologies are used to remember information, filled in on various electronic forms on web pages (e.g. event registration) or when purchasing in the online store.
Tracking cookies are automatically deleted after 12 months.
The purpose and legal bases for processing personal data
The personal data provided will allow us to process your requests and registrations. As a commercial enterprise wishing to flourish in an extremely competitive environment we wish to understand which advertisements attract your attention and we wish to inform you of our services, products and events related to trading and active investing which may be of interest to you.
The personal data will allow us to verify whether you have indeed received the information you requested in a timely manner. It also allows performing a quality control of the services which you requested in order to provide you with the best possible level of service.
The personal data allows us to perform our duties in the framework of legal requirements including, but not limited to, anti money laundering regulations and consumer suitability and appropriateness verification regulations.
The relevant personal data allows us to execute the contract, if applicable, to which you are a party. The execution of the contract may involve the performance of tasks which are in the public interest including but not limited to market stability and transparency obligations.
The legal bases for requesting the personal data are therefore the following:
- Consent from the personal data provider to store and process the data for specific purposes.
- Obligations emanating from a contract.
- Obligations emanating from legal requirements in order to comply with the law.
- Legitimate interests of our company.
- The performance of a task which in the public interest.
The management of personal data
We make it a priority to protect your confidential details, regardless if you are in contact with us by telephone, e-mail, internet or a non-electronic form. WH SelfInvest is continuously making efforts to conform to industry norms to store your data in a safe IT environment, in paper files as well as in other records. Safety measures are taken in order to avoid any unauthorised access and usage, editing, circulation or destruction. We make use of firewalls, authentication systems and various control mechanisms concerning security when accessing our systems and data.
The persons who have access to the personal details are experienced and are aware of the importance of the confidentiality of the client details and respect of the privacy of the individual.
Shortcomings or violations in these requirements could mean these persons are subject to sanctions ranging up to termination of employment. A department head will ensure the correct application of the legislation in order to protect personal details.
The length of time personal data is stored and, if applicable, processed
In the case of personal data provided by prospects we stop communicating after 48 months unless the prospect unsubscribes before. This rule does not apply to Newsletter subscribers who receive the Newsletter until they cancel their subscription by using the unsubscribe function included in every newsletter. The length of time personal data provided is stored, is mainly determined by legal obligations. In the case of personal data provided by prospects, data is stored for a period of 10 years. After this lapse of time personal prospect data can be deleted upon request. In the case of personal data provided by clients, after termination of the agreement we reduce commercial communications to the absolute minimum or stop communicating all together. The length of time personal data provided by clients is stored, is in principle 30 years.
You are in no way required to provide us with the data which we are requesting. You have the possibility to refuse supplying personal data. In this case it is not ruled out that some specific services cannot be provided.
Your rights related to personal data
Your rights, as detailed in the GDPR, with regard to the personal data provided to WH SelfInvest, are described in detail below.
In order to exercise a right you can contact us in writing or e-mail email@example.com. If you decide to use e-mail, you must use the e-mail address we have on file for you. Only signed requests made by you on your own behalf can be accepted. We will respond to your request within four weeks. A request must follow the format detailed below and must be accompanied by a copy of a valid ID. Provide:
- which right you wish to exercise.
- a detailed explanation of why you feel the need to exercise this right.
- the arguments why the right can be exercised in your opinion.
- a description of your desired outcome.
The right to object
This right allows you to object to WH SelfInvest processing your personal data, if WH SelfInvest does so outside of the legal bases evoked in the section "The purpose and legal bases for processing personal data" or if, according to you, these legal bases do not apply.
- Contractual necessity and obligation.
- Legal obligation.
- The performance of public tasks.
- Legitimate interests.
The right to withdraw consent
If WH SelfInvest has obtained your consent to process your personal data for commercial communications you can withdraw your consent at any time using the unsubscribe function included in every commercial communication as well as the Newsletter.
Clients can unsubscribe from commercial communications but in order to meet our contractual obligations, clients cannot unsubscribe from communications which are deemed important by us.
The right to access your personal data
You can request WH SelfInvest to inform you of the personal data we have on file. We will provide you with the information free of charge unless your request is unfounded or excessive. The information will be provided in a format and lay-out as considered practical and suitable by us.
If you request additional copies of the information, we may charge a reasonable administrative fee. WH SelfInvest may refuse to accept your request. In that case, we will inform you of the legal reason why the request cannot be met.
The right to erase your personal data
You have the right to request WH SelfInvest to delete your personal data. Normally such a request should meet one of the following criteria:
- you consider the personal data is no longer required for the purpose for which it was originally requested.
- you have withdrawn your consent and there is no other valid reason why WH SelfInvest should continue to store the data.
- the personal data have been acquired unlawfully.
We have the right or the obligation to not comply with the request for one of the following reasons:
- the right to freedom of expression.
- the necessity to comply with legal obligations.
- the necessity to perform a public task.
- in the context of legal proceedings.
If your request is valid, we shall take all reasonably steps to erase the relevant data and to inform you when it has been done.
The right to restrict processing of personal data
You have the right to request WH SelfInvest to restrict the processing of your personal data. This means that we can only store your data and cannot carry out any further processing unless:
- you give your consent again either directly or by requesting any of the services as detailed in the section "Personal data".
- further processing is necessary to establish, execute or defend legal claims.
- to protect the rights of another person or for reasons of public interest.
Valid reasons why you can request WH SelfInvest to restrict the processing of your personal data are:
- you dispute the accuracy of your personal data WH SelfInvest has on file.
- you object to the processing of your personal data on the basis of the legitimate interests invoked by us. You can request that the processing of your data is restricted as long as we verify the legal basis or legitimate interests for processing the personal data.
- WH SelfInvest no longer needs the personal data, but you do need the personal data in the context of a legal procedure.
If any third parties are used to perform the processing, WH SelfInvest will inform them about the restricted processing, unless this is impossible or requires disproportionate efforts.
The right to rectification
You have the right to request WH SelfInvest to correct any inaccurate or incomplete personal data that we have on file related to you. If WH SelfInvest believes that it cannot meet your request, we will explain our reasons for this decision.
The right of data portability
You may wish to transfer your personal data to another data controller. This right to transfer data transfer applies to:
- personal data which WH SelfInvest processes automatically i.e. without any form of human intervention.
- personal data provided by you.
The data to be transferred will come in a format as processed by us and in a format and lay out considered to be practical, suitable and correct by us. We may charge a reasonable administrative fee.
The right to lodge a complaint with a GDPR supervisory authority
You have the right to file a complaint with the relevant GDPR supervisory authority.